In the case of Florida Central and Peninsular Railroad Company v. Reynolds in 1901, the U.S Supreme Court dealt with a dispute over land ownership. The railroad company claimed that it was entitled to certain lands under an Act of Congress from 1866 which granted public lands to Florida for the construction of railroads. However, these claims were contested by Reynolds who argued that he had obtained valid title through purchase from other parties before the railroad's grant took effect. The court ruled in favor of Reynolds, stating that at the time when his predecessors acquired their titles, there was no legal impediment preventing them from doing so as they were not aware nor could have been aware about any potential claim by a railroad company due to lack of proper notice or information regarding such grants made by Congress.

The dissenting opinion in the case of Florida Central and Peninsular Railroad Company v. Reynolds argued that the majority's decision was inconsistent with previous rulings regarding railroad companies' liability for damages caused by fires started by their locomotives. The dissent contended that railroads should not be held responsible unless negligence can be proven, as per common law principles. It also pointed out that there were no statutory provisions specifically stating a different rule applicable to this situation. Therefore, it believed the court erred in its judgment against the railroad company without any evidence of negligence or violation of duty on its part.